August 25, 2010, 10:30-12:30

Presented by Christina CoffelOklahoma Department of Environmental

QualityLand Protection Division

Hazardous Waste Compliance Section

Safety & Comfort FirstPublic Announcement (PA)

will alert for all emergencies. In the event of a fire, exit out the front door, gather in the north parking lot for a head count.

No smoking on DEQ grounds. You can smoke across the street.

Vending Machines: Located on the 7th floor, after exiting the elevators, go east to the end of the hall. Break room is on the right.

North

Generator status--------------------------LQG, SQG, CESQGGeneration points-------Main location vs. remote locationsSilver reclamation --------------------Minimum level 5 mg/LTransporter issues----------------Should facility be notifiedReclamation documentation---Manifest use requirementsRinse water discharge----Authorized discharge points only

RCRA1. Waste Determinations:

You need to make waste determinations for all waste generated by the facility. Determinations made by either testing or knowledge of process.

Is it a solid waste?If yes,

Is it a hazardous waste?If yes,

Is it a characteristic waste or a listed waste or both?

If yes, Are there any exemptions that apply?

Waste Determinations Point of Generation:

Waste becomes subject to regulation when:It is removed from the manufacturing process

unit, OR 90 days after the unit is taken out of service if

the waste remains in an inactive unit…”

Apply to both mobile and stationary units.

Waste film—may exhibit the toxicity characteristic for silver (D011)Waste solutions –may exhibit the toxicity characteristic for silver & possibly for corrosivity(D002).

Waste Fixer Waste Developer Waste Rinse Water

If vehicle maintenance performed on site: Used Batteries--may exhibit the toxicity

characteristic for corrosive and lead (D002 &Doo

Used Antifreeze (60/40 Hazardous Guidance)

Used Oil & Used Filters

Used Fluorescent Lamps-- may exhibit the toxicity characteristic for mercury (D009)

Waste FilmUsually contains silver above the RCRA limit of

5.0 mg/L using TCLP. Can recycled under the precious metals

exemption, 40 CFR 266 Subpart F.Hazardous waste determination:

Can either test film (TCLP) to determine level (make sure test is a representative sample of all possible exposures for accurate silver levels)

OR, assume it will exhibit the toxicity characteristic for silver.

OR, use knowledge of process—supporting information/documentation required.

Waste SolutionsWaste Fixer & Waste Developer & Waste Rinse WaterCan be separated in process to reduce quantity of HW

generated or combined into one waste container.Silver recovery unit must be used as per the manufacturers

instructions. Periodic testing should occur to ensure recovery unit is operating at

optimum levels.

After recovery, the waste waters should be below RCRA limit of 5 mg/L silver. May need more than one recovery unit to accomplish this. Recovery cartridges are considered a sludge if going for recovery, not a

RCRA wasteso you don’t have to count their weight in your monthly generation amounts (see future slide)

If you use test strips, verify the range of the strip!

Used LampsLamps qualify to be managed under the Universal

Waste (UW) regulations which are less stringent than the full hazardous waste regulations.

UW containers must be compatible, labeled, and dated with an accumulation start date or tracking system.

One year storage limit vs. 90-day (LQG), or 180-day (SQG).

No manifest usage required. Bill of Lading sufficient or internal tracking system.

Does require UW employee training.

Vehicle WastesUsed Oil (UO) & Used Filters 40 CFR 279 Label Containers “USED OIL” Use authorized UO Recycler & Transporter

Used Antifreeze: EPA 60/40 Hazardous Guidance

Vehicle Wastes cont…Used BatteriesCan be managed as HW, UW, or under

special exemption: 40 CFR 266 Subpart GIf core-exchanging, then it is easiest to use

the exemption.Generators responsible to ensure proper

recycling is occurring by the company accepting the battery for recycling-perform due diligence before sending for recycling

RCRA2. Generator Status Determinations:You need to determine how much hazardous waste you

will generate each month in order to establish which hazardous waste generator category you will be in.

Large Quantity Generator (LQG)generate over 2, 200 pounds HW per month

Small Quantity Generator (SQG) generates 220 to 2,200 pounds HW per month

Conditionally Exempt Small Quantity Generator (CESQG)generates 0 to 220 pounds HW per month

Only count the hazardous waste weight!

Do not count waste that is managed as Universal Waste.

Do not count Used Oil.

LQGs 2,200 lbs or more HW generated monthly

Required Notification for an EPA ID# Must use a manifest/LDR Disposal Plans & Annual FeesQuarterly Reports & Biennial ReportsWritten Contingency/Emergency Plans

LQGs cont…Notification to local authoritiesWell documented Employee Training

ProgramsDocumented weekly HW storage inspections 90-day HW storage limits & NO weight limit

for storageStorage containers must be closed,

appropriately labeled, and datedMust perform and document weekly storage

area inspections

SQGs 220 lbs –2,200 lbs HW generated monthly

Required Notification for an EPA ID#

Must use a manifest /LDRAnnual FeesWritten Contingency/Emergency

Plans

SQGs cont…Notifications to local authoritiesEmployee training ProgramsWeekly HW storage inspections 180-day HW storage limits & no more

than 13,228 lbs (6,000 kg) on site at any given time

Storage containers must be appropriately closed, labeled, and dated

CESQGs Up to 220 lbs HW generated monthly

Not required to notify EPANot required to use a manifest, bill of lading

sufficient Destination facility must be authorized to

accept the wasteRecycling facility must be a legitimate recyclerLimited to no more than 2,200 lbs HW on site

at any given timeNo time limit for storage

Storage vs. Satellite AccumulationDefinition of CLOSEDLabelingAccumulation start date

Container ManagementSatellite Accumulation Area

At or near the point of generation,Under the supervision of the operator, Not exceeding 55 gallons per SAA, Only three day allowance to move full SAA to container

storage.

Storage containers are used to store hazardous waste awaiting disposal or recycling. Usually stored in a centralized location.

The amount of storage is limited by the generator status. No limit on the number of SAA allowed.

Container ManagementBoth types of containers must be

closed. DEQ defines closed as spill proof and vapor tight.

Both containers must be labeled. Storage with the words “Hazardous Waste”, SAA with a content identifying label.

Container ManagementStorage containers require an accumulation

start date on the container. identifies the first day the container became a

storage container. This date will show how long it has been on site so as to comply with the generator storage limits (90-days LQG or 180-days SQG).

A SAA may become a storage container when it is deemed full or moved to the container storage area. At this point it needs a date and the words

“Hazardous Waste”.

40 CFR 266 Subpart F: Silver Reclamation

Silver Reclamation ExemptionMaterials that are reclaimed to recover

economically significant amounts of gold, silver, platinum, palladium, iridium, osmium, rhodium, ruthenium, or any combination of these.

Applicable to any persons who generate, transport, or store recyclable materials that are regulated under this subpart. Required to:Notify EPAUse the manifest if a generator, transporter, or

someone who stores.

Silver Reclamation ExemptionAnyone who stores recycled materials that are

regulated under this part must keep the following records to document they are not accumulating these materials speculativelyRecords showing the amount of materials stored at the

beginning of the calendar year;The amount of these materials generated or received during

the calendar year; and The amount of material remaining at the end of the calendar

year.

If speculative accumulation occurs, all regulations apply!

If sent out of the country, specific EPA reporting required.

Generating at a remote location and transporting the hazardous waste back to the main location

Transporting Hazardous WasteRequires: EPA notification of activity,Licensing from DOT,Authorization from OCC.

Knowledge of manifesting requirementsSpecific employee/driver training

Transporting Hazardous WasteIf generator is a CESQG:

Can self transport (limited amounts). No HW manifesting required.Be very familiar with the CESQG exemption--

40 CFR 261.5Be careful with timing of waste generation,

this may affect your generator category. Some CESQGs can become SQGs based on the timing of waste disposal. Then all SQG rules apply for that month of SQG generation.

http://www.deq.state.ok.us/LPDnew/HW/Industrial%20Radiography%20Silver%20Recl%20from%20Xray%20Develpmt%2011-2010.pdf

Hazardous Waste Compliance Section Phone

Mike Edwards, ManagerChristina Coffel, InspectorAl Coulter, Data

ManagementJarrett Keck, ReportingAny other HWCS memberFacsimile

(405) 702-5226

(405) 702-5176

(405) 702-5189

(405) 702-5219

(405) 702-5100

(405) 702-5101